SecProbe.io

CORRESP
 1
 filename1.htm

 March
13, 2026

 Via
Edgar Transmission

 Ms.
Irene Paik / Ms. Sandra Hunter Berkheimer

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Crypto Assets

 Washington,
D.C. 20549

 Re:
 Tron
 Inc. (the " Company ")
 Amendment
 No. 3 to Registration Statement on Form S-3
 Filed
 February 6, 2026
 File
 No. 333-288986

 Dear
Ms. Paik / Ms. Berkheimer,

 We
hereby provide a response to the comments issued in a letter dated March 2, 2026 (the "Staff's Letter") regarding the
Company's Registration Statement on Form S-3 (the "Registration Statement"). Contemporaneously, we are filing the revised
Registration Statement via Edgar (the "Amended S-3").

 In
order to facilitate the review by the Commission's staff (the "Staff") of the Amended S-3, we have responded to the
comments set forth in the Staff's Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff's
comments and correspond to the numbered paragraph in the Staff's Letter.

 Amendment
No. 3 to Registration Statement on Form S-3

 Risk
Factors, page 17

 1.
 Please
 disclose the location of your auditor's headquarters. Disclose that trading in your securities may be prohibited under
 the Holding Foreign Companies Accountable Act, as amended by the Consolidated Appropriations Act, 2023, and related regulations
 if the PCAOB determines that it cannot inspect or investigate completely your auditor for a period of two consecutive years,
 and that as a result an exchange may determine to delist your securities.

 Response:
 In response to the Staff's comment, the Company has revised the disclosure on page 30 of the Amended S-3.

 In
2023, the PRC government initiated a series of regulatory actions and statements, page 39

 2.
 We
 note your disclosure in the risk factor heading that "[i]n the future, [you] may be subject to PRC laws and regulations related
 to [your] current business operations." Please revise to clarify that the legal and operational risks associated with operating
 in the PRC also apply to any current or future operations in Hong Kong.

 Response :
In response to the Staff's comment, the Company has revised the disclosure on page 41 of the Amended S-3.

 W e
may become subject to a variety of PRC laws and other obligations regarding M&A Rules, page 40

 3.
 We
 note your disclosure here and throughout regarding your belief or your management's understanding that you are not subject
 to certain PRC laws and regulations. To the extent your disclosure is based on an opinion of Hong Kong or PRC counsel, please identify
 counsel and file the consent of counsel as an exhibit to the registration statement. If you did not consult counsel, please disclose
 that an opinion was not obtained.

 Response :
In response to the Staff's comment, the Company has revised the disclosure on page 42 of the Amended S-3. The Company has
not obtained an opinion from PRC or Hong Kong counsel.

 It
may be difficult to enforce a judgment of U.S. courts for civil liabilities, page 42

 4.
 We
 note your disclosure in response to prior comment 3 regarding the difficulty of enforcing civil liabilities in Hong Kong and China.
 Please clarify whether you have any directors or officers located in China. In addition, to the extent your disclosure is based
 on an opinion of Hong Kong or PRC counsel, please identify counsel and file the consent of counsel as an exhibit to the registration
 statement. If you did not consult counsel, please disclose that an opinion was not obtained.

 Response :
In response to the Staff's comment, the Company has revised the disclosure on page 44 of the Amended S-3. The Company
has not obtained an opinion from PRC or Hong Kong counsel.

 *
* *

 Please
reach Ted Paraskevas, the Company's outside counsel at +1 212-407-4971 if you would like additional information with respect to
any of the foregoing. Thank you.

 Sincerely,

 /s/
 Richard Miller

 Richard
 Miller

 Chief
 Executive Officer